IR 05000445/1989082
| ML20011D345 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/14/1989 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20011D344 | List: |
| References | |
| 50-445-89-82, 50-446-89-82, NUDOCS 8912270006 | |
| Download: ML20011D345 (15) | |
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION REGION IV-NRC Inspection Report:_ ~ 50-445/89-82 Construction Permits:
CPPR-126 50-466/89-82 CPPR-127 i
Dockets: 50-445 L
50-446-
' Licensee: TU Ele'etric-Skyway Tower 400 North Olive, L.B. 81 g
Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES)
Inspection At: CPSES Site, Glen Rose, Texas Inspection Conducted: November 13-17, 1989-Inspector:
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J/ B. Nicholas, Sen{or Radiation Specialist Date 4acilities Radiological Protection Section Approved:
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/.urray, Chief, Fa:ilities Radiological Date B
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Inspection Summary Inspection Conducted November 13-17, 1989 (Report 50-445/89-82; 50-446/89-82)
. Areas Inspected:
Routine, announced, preoperational inspection of the-applicant's Unit l'and Unit 2 liquid and gaseous radioactive waste systems,
-radioactive waste management program, water chemistry and radiochemistry programs, and_ plant systems affecting plant water chemistry.
Results: The applicant's radwaste section was fully staffed except for an offer still outstanding to fill the last radwaste operator's position. The
.radwaste' management and staff possessed sufficient experience and training to
. adequately support plant operations. The radwaste section had been attentive
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to NRC concerns and had addressed them in a timely manner. The inspector
' determined that the applicant had established a radioactive waste management-program to provide the required support for plant startup and operation.
Within the area inspected, no violations or deviations were identified.
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~8912270006 891218 PDR ADOCK 05000445 Q
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DETAILS 1.
Persons Contacted-TV Electric
- C. B. Hogg, Chief Engineer
- 0.'Bhatty,. Quality Assurance (QA) Issue Interface Coordinator
- D. M. Bozeman, Chemistry / Environmental Engineer
- H.' J. Brau, Nuclear Operations Engineering Supervisor
- C. E. Carter,. Nuclear Operations Special Project Engineer
- D. Corbitt, Administrative Services Manager
- G. G.-Davis, Nuclear Operations Open Item Coordinator
- D. L. Davis, Nuclear Operations Technical Support
- F, D.'Dunham, QA Issue Interface Coordinator
- J. D. Edwards, Corporate Health Physics Supervisor J.-M. Edwards, Radwaste Operations Aide T. L. Edwards, Radwaste Operator R. E. Fishencord, Radiation Protection Supervisor
- R. Flores; Nuclear Operations Support Manager
- K-- R. Harding,' Nuclear Operations Plant Evaluation
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- N. S. Harris,-QA Deficiency = Analysis
- J. C. Hicks, Licensing Compliance Manager
- T. A. Hope, Site Licensing
- D. L.-Hubbard, Technical Training Manager D. C. Kay, Corporate Health Physics Senior Engineer
- C Kesinger, Training Accreditation Adviser
- G. J. Laughlin, Instruments ana Controls Manager
- S. R. Lueders, Radwaste Supervisor
' C L. Mansfield, Radiation Protection Engineer
- F. P. Miller, QA Audit Engineer G. P. Moore, Chemistry Supervisor G. Ondriska, Startup Technical Support Supervisor
- E. J. Schmitt, Radiation Protection Manager
"J. C. Smith, Plant Operations
- S. W. Swam, Training Supervisor
- W. G. Westhoff, Quality Audit Manager
- B. W. Wieland,. Maintenance Manager NRC R. F. Warnick, Assistant Director for Inspection Programs, CPPD, NRR
- S. D. Bitter, Resident Inspector, Operations
'*J. S. Wiebe, Ser.'.or Project Inspector for Inspection Programs
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- E. F. Ottney, Program Manager, Citizens Association for Sound Energy-(CASE)
- 0. L. Thero, CASE
- Denotes those present during the exit meeting on November 17, 1989,
2.
Followup on Previous Inspection Findings (Closed) Open Item _(445/8929-01; 446/8929-01):
Radwaste Organization -
This item was identified in NRC Inspection Report 50-445/89-29; 50-446/89-29 and involved the lack of a formal radwaste organization and staff to manage and perform operational radwaste activities.
The inspector. reviewed the applicant's organizational-structure which showed a radwaste section within the operations department.
The radwaste section was staffed with a radwaste supervisor, an operations aide, and nine radwaste operators.
The applicant had written administrative procedures-which described specific responsibilities and duties for the radwaste supervisor and radwaste operators.
The applicant had written operating procedures for the various radwaste systems.
The procedures reviewed are listed in the Attachment to this report.
The inspector reviewed the education ard experience backgrounds of the present radwaste-operations staff and verified that they met the required qualifications specified in
.the Final Safety Analysis Report (FSAR) and the draf t Technical Specifications (TS).
The inspector reviewed the training / qualification records of the radwaste operators and determined that six of the nine radwaste operators had completed their auxiliary operator qualification training and had received radwaste systems operation certification.
The inspector found the applicant's radwaste organization and staffing adequate to close this item.
(Closed) Open Item (445/8929-02; 446/8929-02):
Liquid Radwaste System -
This item was identified in NRC Inspection Report 50-445/89-29; 50-446/89-29 and involved the_ completion of the preoperational liquid
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radwaste systems tests and approval of the test results by the Joint Test Group (JTG).
The inspector reviewed the results of the follow'ing liquid radwaste system preoperationti tests:
ICP-PT-41-01 SFT, " Liquid Waste Processing System Channel B," performed during the period September 29 through October 31, 1989; ICP-PT-41-02 SFT, " Waste Evaporator / Liquid Waste Processing System Channel A," performed during the period September 18 through October 18, 1989; ICP-PT-41-04 SFT, " Reactor Coolant Drain Tank Subsystem of the Liquid Waste Processing System," performed during the period February 22 through June 8, 1989; and 1CP-PT-56-01 SFT, " Boron Recycle System," performed October 3-18, 1989.
The test results satisfied the specified criteria.
(0 pen) Open Item (445/8929-03; 446/8929-03):
Gaseous Radwaste System -
This item was identified in NRC Inspection Report 50-445/89-29; 50-446/89-29 and involved the completion of the preoperational test on the gaseous radwaste system and approval of the test results by the JTG and
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.the completion of a full range calibration of the gaseous effluent monitors. The inspector reviewed the results of the gaseous radwaste system preoperational test ICP-PT-61-01 SFT, " Gaseous. Waste Processing System," performed during the period August 26 through October 5, 1989,
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and found that the test results satisfied the specified criteria.
The inspector discussed the calibration of the gaseous effluent monitors with the applicant.
Calibration procedures had not been developed for performing " primary" gaseous calibrations. The applicant had verified
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" transfer" calibration data for the gaseous effluent monitors supplied by-the monitor vendor. The applicant agreed to develop procedures and perform a full range " primary" gaseous calibration of the gaseous effluent
. monitors within.6 months following Unit 1 initial criticality. Therefore, this item remains o, pen pending completion of the " primary" gaseous e
calibration of the gaseous effluent monitors within 6 months following Unit 1 initial criticality.
(0 pen) Open Item (445/8929-05; 446/8929-05): Air Cleaning Systems - This item was identified in NRC Inspection Report 50-445/89-29; 50-446/89-29 and involved the completion of the preoperational tests of the plant air.
cleaning systems and balancing of the Unit 1 ventilation and filtration systems. The inspector reviewed the results of the following air cleaning system preoperational tests:
ICP-PT-45-07 RT-1, " Containment Preaccess Filtration System Filter Test," performed during the period September 27 through October 1, 1989; and XCP-PT-46-02 RT-1, " Hydrogen Purge Exhaust System Filter Test," performed September 27-29, 1989. The test results satisfied the specified criteria. The two remaining preoperational tests for the control room-filtration system and primary plant filtration system will be scheduled when Unit I construction and painting is completed and the high efficiency air particulate (HEPA) filters and charcoal adsorber material has been-replaced in the systems.
The applicant had not completed the balancing of the Unit 1 ventilation and filtration systems.
This' item will remain open pending completion of the following preoperational system tests:
ICP-PT-07-03, " Control Room Filtration System," and 1CP-PT-24-03, " Primary Plant Filtration System," and the completion cf the Unit 1 ventilation'and filtration system balancing prior to obtaining a low power license for Unit 1.
(Closed) Open Item (445/8929-07; 446/8929-07): Audits and Surveillances -
This item was identified in NRC Inspection Report 50-445/89-29; 50-446/89-29 and involved the performance of a comprehensive QA audit of the radioactive waste program. The licensee conducted a QA audit of the radioactive waste control program during the period September 28 through October 6, 1989. No program deficiencies were identified.
The inspector reviewed the QA audit plan, checklist, and QA Audit Report QAA-89-24A for scope and thoroughness of program evaluation. The applicant's performance of a QA audit is considered adequate to close this item.
(0 pen) Open Item (445/8921-02; 446/8921-02):
Primary Chemistry Sampling System - This item was identified in NRC Inspection Report 50-445/89-21; 50-446/89-21 and involved the completion of the startup testing of the Unit 1 Grab Sample Hood Assembly.
The applicant had performed several
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-5-design and equipment modifications on the Unit 1 Grab Sample Hood Assembly panel during the performance of_ the initial startup testing of the panel.
Each of these modifications were in turn inspected and retested by the applicant following their installation. However, due to the number of modifications performed on the Unit 1 Grab Sample Hood Assembly panel, the JTG,made the decision to perform the entire startup testing procedure again. This item remains open pending completion of the startup testing of the Unit 1 Grab Sample Hood Assembly, approval of the test results by the applicant's JTG, and subsequent NRC review and approval of the
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completed startup test procedure prior to Unit 1 initial criticality.
(0 pen) Open Item (445/8921-05; 446/8921-05):
Postaccident Sampling System (PASS) - This item was identified in NRC Inspection Report 50-445/89-21;-50-446/89-21 and involved the completion of the testing and calibration of the PASS in-line analytical instrumentation and the verification of PASS operability. The applicant is in the process of resolving the system's QA deficiencies and is performing PASS in-line instrument calibrations.
This item remains open pending completion of the PASS operability testing as described in the initial open item description prior _to Unit I exceeding 5 percent power.
3.
Inspector Observations
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The following are observations the inspector discussed with the applicant during the exit meeting on November 17, 1989. These observations are not violations, deviations, unresolved items, or open items. These observations were identified for applicant consideration for program improvement, but the observations have no specific regulatory requirements. The applicant stated that the observations would be reviewed.
a.
Waste Evaporator Sampling - The applicant had not provided a sample sink at the sample points for each of the three waste evaporators.
(See paragraph 4.)
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Duratek Liouid Waste Processing System - The applicant had not completed installation of the Duratek liquid waste processing system.
(See paragraph 4.)
c.
Effluent Isolation Valve Testing - The applicant's liquid effluent release permit procedure did not require testing of the effluent radiation monitor isolation capability before each radioactive effluent batch release.
(See paragraph 4.)
4.
Liquid Waste Systems The inspector reviewed the applicant's liquid radioactive waste management program including:
liquid waste system construction and installation, preoperational testing of the liquid waste subsystems, and procedures for controlling liquid effluent releases to determine agreement with commitments in Chapter 11 of the FSAR and compliance with the requirements l
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p The~ inspector inspected the construction and installation of the liquid radwaste systems,- which-are common to both Units 1 and 2, and found that c
the construction andl installation of the designed components were
completed. The applicant had performed the preoperational tests designed-te test the.various liquid radwaste subsystems.
The inspector reviewed
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- the results of the completed preoperational tests listed in.the Attachment g
to this report and found the test results satisfied the specified W*
criteria.
During the inspection of.the facility and equipment, it was noted that the-grab sample points for the concentrate and distillate samples from the
- waste evaporator, boron recycle evaporator, and-floor drain evaporator, were installed very close together for each respective evaporator and no sample-sink and drain had been installed: for purging sample lines and decontaminating the sample bottles. The close proximity of the respective
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evaporator's concentrate and distillate sample points may cause a potential. problem of cross contamination of the samples. These samples
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wilizbe thermally hot" as well as highly radioactive and no provision has
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been made for decontaminating-the sample containars after sampling and
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. prior to _ transporting the samples to _ the laboratory for _ analysis. Also, no-provisions have been made for the control and disposal of the liquid Land solid radioactive waste which will be-generated during the sampling
- process,. This observation was discussed with the' applicant during'the
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inspection and at the-exit meeting on November 17, 1989. The applicant agreed to evaluateLthe inspector's-observation dealing with the potential radiation contamination problems associated with the evaporator sampling.
It was also noted that the Duratek Enhanced Volume Reduction Processing
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System had not been completely installed. This system was not part of the i
original plant radwaste system design and is being added as an enhancement to the originally designed liquid radwaste treatment system installed in the plant.
The applicant indicated that the installation of the Duratek
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system was scheduled to be completed by the end of 1989. The design and description 1of the Duratek system addition to the.l.iquid radwaste d
treatment system had not been added to the FSAR system's description at
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the time.of-the inspection. The applicant stated'that a description of
'the Duratek radwaste processing system would be included in the next-
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revision to the FSAR. The final inspection of the Duratek system will be
performed during future inspections of the radwaste area. The completion-of the Duratek system installation was discussed as an inspector observat en during the exit meeting on November 17, 1989.
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The inspector reviewed approved CPSES procedures for governing the release s
of'11 quid radioactive waste.
It was noted that the applicant's liquid
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effluent release procedure did not require the testing of the liquid i
effluent discharge isolation valve before each batch release by initiating an isolation signal through the alarm / trip setpoint of the controlling
. radiation monitor. This trip or isolation testing is presently scheduled
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quarterly per TS requirements, during the analog channel operational test l
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on the liquid' effluent radiation monitor which provides an alarm and automatic termination of a radioactive liquid effluent release.- The performance testing of L the _ liquid effluent discharge isolation valve before each batch release provides a greater assurance that the radiation monitor alarm / trip setpoint signal will actuate the isolation discharge valve and terminate a radioactive liquid release which would exceed TS limits.. This observation was discussed with the applicant during the exit meeting on November 17, 1989. The applicant agreed to evaluate the inspector's observation involving the frequency of testing to demonstrate that automatic isolation of an effluent discharge pathway occurs if the radiation monitor measures radiation levels greater-than the alarm / trip setpoint.
No violations or deviations were identified.
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Gaseous Waste Systems-The inspector reviewed the applicant's gaseous radioactive waste management program including: gaseous waste system construction and installation, preoperational testing of the gaseous waste systems, and i
procedures for controlling gaseous effluent releases to determine
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agreement with commitments in Chapter 11 of the FSAR and compliance with the requirements ir Section 3/4.11 of the Unit I draft TS and the draft ODCM.
The inspector inspected the construction and installation of the gaseous radwaste systems in _ Unit I and those gaseous systems common to both units i
and found the construction and installation of the designed components complete except for the installation of the HEPA filters and charcoal adsorber material in the Unit I control room filtration system and the Unit l' primary plant filtration system.
The applicant had not completed all of the preoperational tests designed to test the varioui. air cleaning
.i systems throughout the plant. The testing of these air cleaning filtration systems is being tracked by Open Item (445/8929-05; 446/8929-05). The inspector reviewed the results of the completed preoperational tests listed in the Attachment to this report and found the test results satisfied the specified criteria.
The inspector reviewed approved CPSES procedures for controlling _the release of gaseous radioactive waste and found the procedures adequate to i
perform and control gaseous radioactive waste releases.
No violations or deviations were identified.
6.
Systems Affecting Water Quality The inspector reviewed the applicant's water treatment systems including
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construction, installation, and operation of the plant designed systems to determine agreement with commitments in Chapter 10 of the FSAR.
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The inspector reviewed the following water quality systems:
makeup water demineralizers, condensate polishing demineralizers, and chemical and volume control. filters and demineralizers.
The plant's water quality-systems..were installed, tested, and operating to design specifications and producing high quality water.
The inspector reviewed data log sheets from
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March and April 1989 for analyses results of the domineralized water product from the plant water treatment system and the water stored in the demineralized water storage tank. The analyses results showed that high quality demineralized water was being produced in accordance with CPSES proc'edure requirements. The inspector reviewed the applicant's policies and procedures for replacing and regenerating spent demineralizer resins and found them to be satisfactory to control demineralizer performance.
No violations or deviations were identified.
7, Water Chemistry Control and Chemical Analysis The inspector reviewed the applicant's water chemistry program including establishment and implementation of a water chemistry control program and t-a quality control (QC) program for water chemical measurements to determine agreement with commitments in Chapter 10 of the FSAR and compliance with the requirements in Sections 3/4.7.1.4 and 6.8 of the Unit I draft TS.
'The inspector reviewed the applicant's Unit.1 secondary chemistry program and found that=it met the commitments and requirements of the FSAR and the Unit I draft TS.
It was verified that all water chemist y analytical procedures, chemical control procedures, surveillance procedures,
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secondary chemical process systems operations procedures, and laboratory and process instrument calibration and QC procedures had been completed, approved, and tested. The applicant's procedures were adequate to monitor and control the water chemistry program.
The secondary water chemistry limits for the various modes of plant operation were found to be based on Electric Power Research Institute guidelines. The procedures reviewed are listed in the Attachment to this report.
The applicant's water production chemistry laboratory, secondary water chemistry laboratory, and primary chemistry laboratory were fully equipped and operational to support plant operation. The inspector determined that the type and quantity of analytical instrumentation in the plant laboratories to be adequate to support plant operation and perform the analysis requirements as specified in the FSAR and the Unit I draft TS.
The inspector verified that the analytical instrumentation in the plant laboratories had been calibrated and a QC program had been implemented in accordance with CPSES procedures.
No violations or deviations were identified.
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Exit Meeting The inspector met with the NRC and applicant representatives identified in paragraph 1 of this report at the conclusion of the inspection on November 17, 1989, The inspector summarized the scope of the inspection and discussed the closure of three previously identified open items and the status of the remaining radwaste and chemistry open items. The inspector established the time frame for closing each of the remaining open items as stated in paragraph 2 of this report. _The inspector discussed the three inspection observations for program improvement as discussed in paragraph 4 of this report. The applicant acknowledged the inspection findings, observations, and open items and stated that they would take the necessary actions to resolve the remaining open radwaste and chemistry open items prior to their respective deadlines and evaluate the inspector's observations. The applicant did not identify as proprietary any of the material provided to, or received by the inspector during the inspection.
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. Comanche-Psak Steam Electric Station::
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STA-601h Authority;for Equipment Operation
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STA-603, Control:of Station Radioactive 4~
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STA-610 LSecondary Water Chemistry Control
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09/01/89 Radioactive Effluent Releases RPI-706, Radioactive Effluent Tracking
09/01/89
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RPI-707,. Radioactive Effluent Reporting
09/01/89
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Radwaste Systems (RWS) Manual RWS-101A,1 Reactor Coolant Drain Tank System-
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RWS-102, Drain Channel A
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RWS-103, Drain' Channel B
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